In September 2025, ACEEE submitted comments to the Colorado Department of Public Health and Environment (CDPHE) on the Colorado Greenhouse Gas Emissions and Energy Management for Manufacturing (GEMM) Phase 2 facility draft plans. which can lower energy use and reduce greenhouse gas (GHG) emissions through widespread adoption in the state. ACEEE provided general comments on facility plans which centered on consistency across plans with respect to carbon price benchmarking and validation, impact evaluation for disproportionately impacted and residential communities (DICs), suggestions for additional metrics, programs, funding sources for compliance, and additional resources for emerging technologies, thermal re-design, electrification, and industrial heat pumps. ACEEE also provided specific comments on eight (8) Phase 2 draft facility plans that were submitted to the state.
